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Clinical Strategy

Clinical strategy that supports the claims you want to make.

Supplement claims substantiation means holding evidence that supports every claim on your label and in your marketing. We map each claim to the published evidence, show where it falls short, and, where it helps, design a study that closes the gap for the TGA, the FDA and the FTC.

Markets

AU · US

Timeline

From 4 weeks

You receive

A claims-to-evidence plan

CLN

Test your claims.

Three questions. We show what your claims need before they reach a label.

 

Starting from this service

Your pathway

Your pathway

  • Recommended services appear hereWritten output

Question 1 of 3

What this covers

What clinical strategy covers

Every health claim needs evidence behind it, and the standard depends on the market. In Australia, listed medicines must hold evidence that supports each indication, and the TGA can ask to see it at any time. In the US, structure-function claims must be substantiated, and the FTC expects competent and reliable scientific evidence for health claims in advertising.

 

We start with the claims you want to make and work backwards. Each claim is mapped to the evidence for the ingredient, the dose and the form in your product, because a study on a different dose or extract rarely transfers. Where the published evidence is strong, you get a file that shows it. Where it is weak, we tell you plainly, and suggest either a narrower claim or a study that would support the one you want.

 

When a study is the right answer, we design it to be small, focused and useful: the right outcome measures, a realistic sample and a protocol a research partner can run. The aim is evidence that holds up on a label, not a trial for its own sake.

Evidence also protects you after launch. When a regulator, a retailer or a marketplace asks you to support a claim, the answer should be a file you can send the same day. We organise the evidence so it can be read by someone who has never seen your product, with each claim, each study and each dose lined up and easy to follow.

US

WRITTEN OUTPUTS

INGREDIENT STATUS REVIEW

US-01

DSHEA status for every ingredient, with NDI questions flagged.

SUPPLEMENT FACTS LABEL

US-02

Panel, statement of identity and required label copy, laid out for your designer.

STRUCTURE-FUNCTION CLAIMS FILE

US-03

Claims, substantiation and the 30-day FDA notification.

MARKETING AND AMAZON REVIEW

US-04

Website, ads and marketplace listings checked against FDA and FTC rules.

CGMP DOCUMENTATION CHECK

US-05

Supplier and manufacturer paperwork reviewed against 21 CFR 111.

INSPECTION READINESS NOTES

US-06

What an FDA inspector would ask for, and where it lives.

How it works

Four stages, each one in writing.

Every Clinical Strategy scope follows the same four stages. You receive a written output at the end of each, so nothing depends on memory or a phone call.

01

Discovery

We learn the product, where it is sold today and how you plan to sell it in the US.

Written output: Discovery notes

02

Validation

Each ingredient, dose and claim is checked against DSHEA, FDA labelling rules and FTC guidance.

Written output: Validation report

03

Scope

We set out exactly what will be prepared, by whom, and when you will have it.

Written output: Signed scope

04

Build

Label, claims file, notifications and marketing review, delivered to the scope.

Written output: Final compliance file

Who this is for

Claims by category

Vitamins & Minerals

Listed medicines, from single actives to complex multis.

Probiotics

Strain selection, stability and claim wording..

Sports Nutrition

Protein, pre-workout and recovery, food or medicine.

Nootropics

Cognitive claims handled with care.

Functional Foods

FSANZ standards for foods that do more.

Beauty Supplements

Collagen, skin and hair from the inside.

A note from Amelia

“A small study that answers the right question is worth more than a large one that answers nothing on your label.”

Often scoped together

Related services

AU

AUS Regulatory Affairs

TGA and FSANZ pathways for supplements, nutraceuticals, cosmetics and medical devices.

From 6 weeks

US

USA Regulatory Affairs

FDA and DSHEA compliance for dietary supplements and nutraceuticals.

From 8 weeks

AU · US · UAE

New Product Development

From first idea to a specification a manufacturer can quote.

From 8 weeks

Questions

What founders ask about Clinical Strategy.

If your question isn’t here, send it with your enquiry. We reply within two business days.

What is supplement claims substantiation?

It is the evidence that supports each claim you make about your supplement. Regulators expect you to hold it before the claim is made, not after. We build a file that links every claim to studies on the same ingredient, dose and form as your product.

Sponsors of listed medicines must hold evidence that supports each indication on the ARTG and certify that they hold it. The TGA publishes evidence guidelines, and it can request the evidence at any time. We organise your file to those guidelines.

Structure-function claims must be truthful and substantiated. The FTC, which oversees advertising, expects competent and reliable scientific evidence, generally meaning well-designed human studies on the product or an equivalent formula. We assess your claims against that standard.

Not always. Many claims can be supported by published studies on your ingredients at the same doses and forms. A study makes sense when you want a claim the literature does not support, or a point of difference competitors cannot copy.

It can, if it is designed around the claim you want to make. The outcome measure, the dose, the population and the duration all have to match. We design studies to answer one question well.

Yes. Nootropic and beauty supplement claims attract close attention from regulators, so we are particularly careful with wording and evidence in both categories.

Further reading

Reformulating a supplement for different populations and markets

A formula that suits young adults in Sydney may not suit older adults in Los Angeles or families in Dubai. Nutrient needs, diets, cultural requirements, climate and local rules all shift from one population to the next. Here is how we approach reformulating a supplement so it fits the people who will take it.

Read More »

Launching and scaling a supplement brand across markets

Expanding a supplement brand into a second or third country is rarely a copy and paste job. Each market brings its own rules for ingredients, claims, labels and post-market duties. Here is how we help brands sequence their markets, build once and scale without losing control of compliance.

Read More »

Amazon and Shopify listings need the same review as your label

A compliant label does not make a compliant listing. Product pages on Amazon and Shopify carry claims, images and keywords that regulators and marketplaces treat just as seriously as your pack. Here is why your listings deserve the same review as your label, and what to check before you hit publish.

Read More »

Collagen coffee: when your supplement is legally a food

Add collagen to coffee and you might think you have made a supplement. In most cases, regulators see a food. That changes the label, the ingredients you can use and the claims you can make. Here is how classification works for functional foods in Australia and the US, and why it matters early.

Read More »

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